The Supreme Court of India emphasized prioritizing appeals against conviction, especially for aged accused on bail, considering the prolonged delay since the offense.
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INEW DELHI: In a recent ruling, the Supreme Court of India highlighted that
“certain categories of appeals against conviction, particularly where the accused are on bail, should be given priority based on their advanced age and the significant time elapsed since the commission of the offense“
This observation was made while dismissing an appeal in a 36-year-old murder case.
Case Overview
The case before the Supreme Court was an appeal filed by the State of Madhya Pradesh, contesting the judgment of the Madhya Pradesh High Court. The High Court had acquitted the respondents—accused individuals who were initially sentenced to life imprisonment—by modifying their punishment to the sentence already undergone. The appeal was heard by a three-judge bench comprising Justice Abhay S. Oka, Justice Ahsanuddin Amanullah, and Justice Augustine George Masih.
The bench highlighted the necessity of striking a fair balance in the prioritization of criminal appeals. It observed that
“even in cases where the accused are on bail, long-pending appeals—particularly those involving elderly individuals—should be considered for expedited hearings“
The court remarked:
“However, a right balance has to be struck by taking up for hearing even some of the old criminal appeals against conviction where accused are on bail. The old age of the accused and the long lapse of time from the commission of the offence can always be a ground available to give some priority to the appeals against conviction of the accused on bail.”
Background of the Case
The incident in question dates back to 1989. The prosecution alleged that the respondents, acting with a common intention, launched an assault on multiple individuals, including PW-1 (Siroman), PW-2 (Ramadhar), PW-3 (Haripal), PW-11 (Jageshwar), PW-12 (Chiranjeev), and the deceased, Laxman.
The trigger for the conflict was purportedly an incident where PW-1 had cut the tail of a buffalo belonging to the respondents. This led to an altercation, during which the respondents allegedly attacked PW-1, PW-3, and PW-11 while they were working in the fields, causing them simple injuries.
Laxman, the deceased, was initially examined and discharged after receiving medical treatment but succumbed to his condition at a later stage. Additionally, PW-2 and PW-12 suffered grievous injuries, including fractures.
Following the trial, the respondents were convicted under Sections 147, 452, 302, 325, and 323 read with Section 149 of the Indian Penal Code, 1860. The Trial Court sentenced them to life imprisonment. However, upon appeal, the Madhya Pradesh High Court took note of the respondents’ advanced age—one being nearly 80 years old and others above 70.
The High Court also observed that
“the injuries inflicted on the deceased were simple in nature and did not indicate an intent to commit murder. As a result, the respondents were released with the sentence already served.”
Supreme Court’s Reasoning for Dismissing the Appeal
Upon reviewing the matter, the Supreme Court analyzed the medical evidence and the circumstances surrounding the death of Laxman. The court found that
“neither the post-mortem report nor the testimony of PW-17 conclusively established that the injuries inflicted by the respondents were the direct cause of death. Moreover, the fact that the deceased passed away 15 days after the incident raised further doubts regarding the causal link between the alleged assault and his demise”
The court remarked:
“Therefore, there is a serious doubt whether even Section 304 of the IPC could have been applied, as the medical opinion does not support the theory of homicidal death of the deceased. That is why it is not possible to interfere with the judgment of the High Court directing that the respondents-accused should be let off for the offence under Section 304, read with Section 149 of the IPC, on the sentence that has been undergone.”
Additionally, the Supreme Court emphasized the broader concern regarding the passage of time in criminal proceedings. The bench pointed out that
“in cases where convictions entail a life sentence and the appeals are heard after a decade or more, it raises a significant question of fairness if the accused—who have remained on bail for a prolonged period—are suddenly required to return to prison”
Acknowledging that the incident took place 36 years ago, the Supreme Court upheld the High Court’s decision and dismissed the State’s appeal.
This judgment reinforces the Supreme Court’s stance on prioritizing certain appeals based on the circumstances of the accused, particularly in cases involving elderly individuals and significant time lapses since the alleged offense. The ruling highlights the
“importance of balancing the principles of justice while ensuring that undue delays in the judicial process do not result in undue hardship for the accused“
Case Details:
This ruling is expected to have implications on future criminal appeals, particularly in cases where the accused have aged significantly and where long delays have impacted the viability of further incarceration.
Title: State of Madhya Pradesh v. Shyamlal & Ors.
Neutral Citation: 2025 INSC 377
Appellant Representation: Advocates Padmesh Mishra, AOR Pashupathi Nath Razdan, Maitreyee Jagat Joshi, Astik Gupta, Akanksha Tomar
Respondent Representation: AOR Yugandhara Pawar Jha
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